Abstract: On July 8, 2011, in Brady v. NFL, the U.S. Court of Appeals for the Eighth Circuit held that the Norris-LaGuardia Act prevented the injunction of an NFL lockout. In so doing, the court provided to the NFL an additional shield from antitrust scrutiny. This Comment argues that by immunizing NFL lockouts from antitrust scrutiny, NFL players will lose an important bargaining tool: the antitrust challenge.